The OFCCP enforces three laws, which together govern equal employment opportunities for persons employed by federal contractors. These laws ban discrimination and require federal contractors and subcontractors to take affirmative action to ensure that all individuals have an equal opportunity for employment.
We can be your year-round expert on Affirmative Action compliance:
- Assess your affirmative action needs
- Help determine what to do internally vs. outsource
- Customized Affirmative action plan development (or review)
- Adverse impact/impact ratio analysis
- Progress towards goals analysis
- Basic compensation analysis by job title within each job group
- Education of human resources staff regarding affirmative action issues
- Education of managers and supervisors regarding affirmative action
- EEO-1 and Vets-4212 reporting
- Assistance with OFCCP affirmative action compliance audits
- Assistance with recordkeeping requirements
- Assistance with the recruitment process; defining an applicant, applicant self-identification, and applicant tracking
- Provide updates on affirmative action regulations and OFCCP audits
Affirmative Action Basics
There are three different regulations affecting affirmative action plans:
1.) Under Executive Order 11246 an organization needs a written affirmative action plan (AAP) if it is a Federal contractor or subcontractor with 50 or more employees and:
- holds a non-exempt government contract or subcontract of $50,000 or more; OR
- holds Government bills of lading of $50,000 or more, or that could reasonably be expected to total $50,000 or more in a year; OR
- service as a depository of Federal funds in any amount; OR
- is an issuing and paying agent for U.S. savings bonds in any amount.
2.) Organizations are required to develop and maintain a Section 503 AAP if they hold a non-exempt Government contract or subcontract of $50,000 or more and are a contractor/subcontractor with 50 or more employees.
3.) Organizations are required to develop and maintain a VEVRAA AAP if they are a contractor or subcontractor with 50 or more employees and:
- hold a non-exempt Government contract or subcontract of $150,000 or more
New Government contractors and subcontractors subject to the AAP requirements must develop an AAP within 120 days from the start of the contract or subcontract. Thereafter organizations are required to develop and maintain AAPs annually.
Affirmative Action Plans have narrative analytical information within the plans. Plans need to contain:
- Organizational profile of the company’s workforce
- Job group analysis
- Utilization analysis to determine whether or not women and minorities are underutilized by the organization.
- Establishing placement goals to measure progress toward achieving equal employment opportunity.
- The plan will designate responsibility to direct, manage, and ensure the implementation of the organization’s affirmative action program.
- Identify problem areas by organizational units and job groups.
- Develop and execute action-oriented programs designed to eliminate problems and accomplish stated goals and objectives.
- Internal audit and reporting system to measure the effectiveness of the affirmative action efforts of the organization.